HOGANGUARDS LIMITED (HGL, We, Our), we understand the importance of privacy, with particular reference to information or personal Data / Information shared by Data / Information Subjects (you, your) and we continually strive to ensure the protection of Data / Information collected at the highest level and the extent permissible by all relevant laws.
This policy constitutes our intention and commitment to ensuring your privacy when using our website, social media or digital platform, applications, newsletter, services, content, technologies, blog and within our premises (Hogan Tools). It details the policy guiding the collection, use, storage, processing, destruction and disclosure of personal Data / Information of Data / Information Subjects.
It is pertinent to note that for the purpose of this policy, HGL is the Data / Information controller. Also, this policy is given and bound by the provision of the Nigeria Data / Information Protection Regulation 2019.
This policy describes your privacy rights, with regards to personal Data / Information collection, use, storage, sharing/ transfer, processing and protection. It also highlights the measures taken to protect Data / Information collected through various means and platforms. Sincerely
As a Data / Information Subject of Hogan tools, you have the following rights, which may be exercised by contacting email@example.com.
You accept this policy and give consent to HGL to obtain and process personal Data / Information upon access to the Hogan tools, either for enquires, official or non-official purposes.
This policy may be amended from time to time and all HGL tool Data / Information Subjects shall be notified by the posting and pasting of the revised version in a conspicuous way and place.
Also, we may collect and use Data / Information provided by third parties like social media/ digital platforms, search engines etc. and the security/protection of information so released and collected shall not be within the purview of HGL’s control. HGL shall therefore not be responsible for the collection, use or processing.
We obtain Data / Information from your computer, mobile device and other electronic access device through the following ways:
Personal Data / Information:While using our services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data / Information”) and this includes name, email address, phone number, date of birth etc. it also includes information contained in Curriculum Vitae.
Location Data / Information: If location detection services have been enabled on your computer, mobile device or other electronic device used in accessing Hogan tool, we may collect details on your location to enable the rendering of more efficient services to you. If you do not want us to collect location Data / Information, please deactivate location detection service.
Log information: this information is collected automatically, gathered and stored by most websites. This information includes: IP addresses, internet service provider (ISP), operating system, date/ time stamp, exit pages, device ID, model and manufacturer etc.
Mobile Device Access: We may request access or permission to certain features from your mobile device, including your mobile device’s camera, calendar, bluetooth, contacts, storage and other features. If you wish to change our access or permissions, you may do so in your device’s setting.
Cookies Data / Information: These are small pieces of information (text files) sent from the website (Hogan tool) to the Data / Information Subjects device and stored on the hard drive. These files are used to ensure Data / Information Subject satisfaction and a more efficient experience while using the tool. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may be unable to use or access some portions of Hogan tools or our services.
Generally, the information collected from Data / Information Subjects is to enable us provide a seamless and easy experience while using Hogan tools, to ensure requests are responded to timeously and transactions processed appropriately. The usage of Data / Information may be extended whenever required, to meet legal, regulatory, statutory, contractual or judicial obligations and other legitimate business concerns. Use of Data / Information may include but not limited to the following:
Transfer of Personal Data / Information to a Foreign Country
Provided, in all circumstances, that the Data Subject has been manifestly made to understand through clear warnings of the specific principle(s) of Data / Information protection that are likely to be violated in the event of transfer to a third country, this proviso shall not apply to any instance where the Data / Information Subject is answerable in duly established legal action for any civil or criminal claim in a third country.
The security of your Data / Information is important to us. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet it itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our services is at your own risk. You should only access the services within a secure environment.
All Data/ Personal information collected, shall be retained, stored, deleted and destroyed by Hoganguards Limited in line with statutory, legislative and regulatory requirements.
The length of storage of personal Data/ Information obtained by HGL, shall to the extent permissible under the governing laws and HGL’s policy on document retention be determined by:
(a) the terms of contract between HGL and the Data Subject or for as long as is needed for the purpose for which it was obtained;
(b) whether the transaction, contract or relationship between the parties has statutory implication or a statutory retention period; or
(c) whether there is an express request for the destruction/ deletion of Personal Data / Information collected by the Data / Information Subject, provided that such request will only be treated where the Data / Information Subject is not under any investigation, legal or judicial obligation ,which may require the retention or production of such Personal Data / Information or there is no subsisting contractual or pre-contractual arrangement with the Data / Information Subject that would require the further processing of the Personal Data / Information; or
(d) whether HGL has a lawful or legitimate basis for retaining that information beyond the period for which it is necessary to serve the original purpose.
In line with NDPR, HGL shall be entitled to retain, store and process Personal Data / Information collected for the purpose of archiving, scientific research, historical research or statistical purposes for public interest.
HGL shall destroy/ delete Personal Data / Information in in her possession where it is no longer required by HGL or in line with HGL’s Document Retention Policy, provided HGL is not required by law or regulation to retain or further process such Personal Data / Information.
For question, comments and enquires on this policy, our compliance data protection officer may be contacted by email: firstname.lastname@example.org or by post: The Data Protection Officer, Block 1 Plot 8 Aduke birogba Industrial Avenue, Km 5 Lagos- Ibadan Expressway, Riverview Estate, Isheri, Ogun State.